Fall Protection Legislation
Fall Protection Legislation
When working to achieve fall protection compliance, two different resources come into play. First, OSHA regulations are the law—essentially the bare minimum thresholds that must be met to avoid penalty. Secondly, consensus standards published by the American National Standards Institute (ANSI) provide a more current and thorough view of how to plan, implement and manage a fall protection program. As OSHA and ANSI both work to reverse the trend of increasing fall fatalities, each entity is updating its information.
Since the currently enforced OSHA general industry regulations were published in 1971, they do not reflect the advancements made in fall protection industry standards, processes and equipment throughout the past 40 years. In fairness to OSHA, federal legislation must be passed to change the regulations. They must be written to apply to all industries and organizations, and, unfortunately, politics or special interests can also play a role in derailing progress. With that said, the process to publish an ANSI standard is simplified and, in turn, more efficient. Fall protection is now a focus area for OSHA since it is regularly at the top of the organization’s list for violations, both in number and penalties. Thankfully, with the release of proposed changes to the 29 CFR 1910 general industry fall protection regulations in May 2010, OSHA is now working to become more relevant for today’s industry practices. Although the period for public comment on the 292-page proposed document ended in late August 2010, OSHA will be working with a variety of industry representatives in the coming months to edit the draft rules in forums such as public hearings—the first of which is January 18 in Washington D.C.
Today, the ANSI Z359 standards provide more guidance than any single resource for developing and implementing a fall protection program. In November 2007, ANSI released a comprehensive family of standards, known as the “Fall Protection Code,” to help organizations learn how to reduce risk. To provide even more guidance—particularly related to active fall protection systems—ANSI published additional standards in November 2009. The organization has plans to release additional subsections of the standard throughout the coming years to provide detailed information on each component of a fall protection solution. The ANSI Z359 standards released in 2007 not only provide an update to the previous Z359.1 standard (1992) on personal fall arrest systems, but they also give more detailed guidance on comprehensive managed fall protection programs (.2), positioning and travel restraint systems (.3), and rescue (.4). Some of the key changes included in the standards became immediately visible and effective due to changes in equipment. For example, the required snaphook gate strength changed significantly from the previous standard of 220 pounds (front load) and 350 pounds (side load) to the 2007 standard of 3,600 pounds for both front and side loads. It is important to note that snap hooks designed to the Z359.1-1992 (R1999) standard still meet the OSHA regulation for a locking snaphook. Many times standards or rules are changed to correct unsafe equipment. This was not the case with the 2007 standards. The changes serve to enhance safety – to make workers at heights safer and at less risk for injury.
MANAGED FALL PROTECTION PROGRAMS
The information provided in the ANSI Z359.2 standard on managed fall protection programs fills a void that OSHA regulations have never been able to fill. The elements of a fall protection program, as outlined in the ANSI Z359.2-2007 standard, are foundational for creating a program that reduces risk and improves safety for work at heights. When one or more of the elements is missing, a program can become stalled or be deemed ineffective. The program elements outlined in the ANSI Z359.2-2007 are: - Policies, duties and training - Fall protection procedures - Eliminating and controlling fall hazards - Rescue procedures - Incident investigations - Evaluating program effectiveness With thorough information on each of these distinct elements, the ANSI Z359.2 standard can help you establish a managed fall protection program or improve on one specific aspect. For example, in the procedures section, the standard gives detailed information on fall hazard surveys, which represent a critical step toward identifying and prioritizing fall hazards. Once you understand the magnitude of fall hazards and potential risks associated with them, an initial validated budget can be created. Then, a phased implementation plan can be developed based on priorities and budget. Although it is beneficial to successfully abate any fall hazard, without a true fall protection program, you may be spending resources on solutions that do little to reduce your overall risk. When pieces of the program are not considered together, they often become costly, ineffective, and inefficient.
The ultimate goal for both OSHA and ANSI is to increase safety and reduce risk for workers at heights. With so much change and so much focus on fall protection.